Publication Plan April 2024

Comment

Representation ID: 5684

Received: 03/05/2024

Respondent: Amadis Holdings Ltd

Agent: PlanIt

we are satisfied that the Plan period presently meets the test of soundness. However, if there are delays in the adoption of the Plan then it may be necessary to extend the plan period. In that scenario, the Council may need to allocate additional housing sites to address any increase in the housing requirement.

Comment

Representation ID: 5685

Received: 03/05/2024

Respondent: Amadis Holdings Ltd

Agent: PlanIt

Mismatch between the pool of employment opportunities in the District and the working age population. There is also a mismatch between existing housing stock and future housing need.

'The Issues and Challenges for South Staffordshire’ section of the Plan should be re-drafted to reflect the fact that the housing and employment requirements are an opportunity for the local economy.

Object

Representation ID: 5686

Received: 03/05/2024

Respondent: Amadis Holdings Ltd

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Local Plan fails to remove land from the Green Belt and safeguard it for development in order to ensure that the Green Belt is not continually reviewed through each Local Plan review.

Policy DS1 should confirm that safeguarded land has been identified for future development to ensure that Green Belt boundaries endure beyond the plan period in accordance with provisions of paragraph 148 of the Framework. Additional sites should be safeguarded accordingly for this purpose. Our client’s land adjoining Yew Tree Lane, nr Wolverhampton could be included within the list of safeguarded sites.

Object

Representation ID: 5687

Received: 03/05/2024

Respondent: Amadis Holdings Ltd

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? No

We are concerned that the suggested housing requirement of 4,726 dwellings fails to meet the housing need of the Greater Birmingham and Black Country. The SSHMA fails to correctly factor in affordable housing need. The draft plan seeks to rely upon affordable housing delivery from the 640 dwellings proposed to meet the growth requirements of the conurbation to support the South Staffordshire affordable housing need. This is inappropriate given that these 640 dwellings are proposed to meet the growth requirements of the conurbation which has its own affordable housing needs. No consideration has been given to increasing the minimum Standard Method housing figure to reflect the local authority’s economic growth aspirations and the fact that the age profile of South Staffordshire is increasing resulting in a decrease in the ‘pool’ of working age demographic.

Housing shortfalls across the HMA are significant as evidenced by the emerging Birmingham Plan and the now aborted Black Country Plan and we are therefore concerned the plan target is too low. it is important that the Council makes the best use of the sites which the Plan allocates for housing development. If additional sites are required for allocation, then there is an opportunity to allocate land at Yew Tree Lane, nr Wolverhampton.

Object

Representation ID: 5688

Received: 03/05/2024

Respondent: Amadis Holdings Ltd

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The housing requirement suggested by policy DS4 is
inadequate. We have provided a detailed explanation of our views on this matters in our response to Table 7 – Housing Target.The housing requirement in the Plan should be based upon the minimum Standard Method housing figure, upwardly adjusted to take account of
affordability factors and economic growth objectives.
Based on our calculations,the Plan seeks to accommodate just 1% of the unmet housing need arising from the conurbation. This is completely inappropriate, given the functional relationship between South Staffordshire and the conurbation with limited opportunities for the housing needs of the conurbation to be met elsewhere.

Object

Representation ID: 5689

Received: 03/05/2024

Respondent: Amadis Holdings Ltd

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Spatial Housing Strategy is flawed. Whilst we have no
particular concern with the majority of development being directed to the larger settlements, a significant increase to the overall housing requirement is required Additional development should be directed to the district’s settlements and adjacent to the urban edge of Wolverhampton to meet the increased housing target

Object

Representation ID: 5690

Received: 03/05/2024

Respondent: Amadis Holdings Ltd

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Land to the west of Yew Tree Lane should be removed from the Green Belt and allocated for residential development. The allocation would deliver a
number of benefits, including the provision of much needed market and affordable housing and new public open space immediately adjacent to the built-up edge of
Wolverhampton. The site is a logical location for development with strong defensible Green Belt boundaries in the form of well-established hedgerows.

Policy SA3 should be amended to include the additional land which is identified by these representations within the list of allocated sites for a minimum capacity of 120 homes.The Plan is presently unsound because of its failure to identify Safeguarded Land to meet the district’s longer term housing needs without the need for further
reviews of the district’s Green Belt boundaries. If this site is not included as an allocation, it should be identified as Safeguarded Land within a new policy.